GR-21-P007 - Bransford Parcels PCA-S-79-C and PCA-S-79-B - Request
Parr Brown Gee & Loveless, A Professional Corporation
101 South 200 East, Suite 700, Salt Lake City, UT 84111
T 801.532.7840 F 801.532.7750 www.parrbrown.com
JEREMY M. BRODIS
ATTORNEY AT LAW
jbrodis@parrbrown.com
November 23, 2021
VIA EMAIL AND U.S. MAIL
Mark Harrington
Senior City Attorney
Park City Municipal Corporation
445 Marsac Avenue
P. O. Box 1480
Park City, Utah 84060
Re: GRAMA Request for Records Relating to Certain Parcels of Real Property
Identified as Parcels PCA-S-79-C and PCA-S-79-B
Dear Mr. Harrington:
I represent RH Mayflower, LLC (“Requester”) with respect to the matters that follow.
Pursuant to the Utah Government Records Access and Management Act (“GRAMA”), Utah
Code sections 63G-2-101 et seq., Requester hereby requests to receive from Park City copies of
the following records:
For the period of time of April 2021 to the present, any documents and
communications exchanged between Park City (including anyone acting on its
behalf), on the one hand, and Bransford Land Company LLC (a.k.a.
Bransford Land Company, L.L.C.) (including anyone acting on its behalf), on
the other, that refers or relates to either or both of the following parcels of real
property: (1) “Logan Mining Claim” (a.k.a. Parcel PCA-S-79-C); and (2) “UP
No. 2 Lode Mining Claim” (a.k.a. Parcel PCA-S-79-B).
Without intending to limit the scope of the foregoing request, but rather to aid in the
location of responsive documents and reduce associated search times, it is our understanding that
Bransford Land Company LLC, or someone acting on its behalf, has submitted to Park City one
or more rezoning or other land use applications in connection with the above-identified parcels.
This request seeks copies of all such applications, as well as any additional correspondence or
other documents exchanged either before or after the application(s) that relate to any land use
issues associated with the aforementioned parcels.
Park City
November 23, 2021
Page 2
Again without intending to limit the scope of the request, we understand that one or more
of the following individuals or entities may have been involved, and Requester respectfully
requests that all of the following, in addition to Bransford Land Company LLC, be considered
relevant terms for the generation of search terms for identifying responsive documents:
(A) Bransford Family Trust;
(B) Anne L. Bransford (or Ann Bransford, formerly known as Anne B. Newhall);
(C) Mary Leader (or Mary Bransford Leader);
(D) Carolyn (or Caroline) Bransford (or Carolyn (or Caroline) Bransford McDonald);
(E) Jonathan Niefedlt;
(F) Thomas Bachtell;
(G) Stephen Horvat; and
(H) Flagstaff.
To account for the common misspelling of the surname and company name of the
relevant parties, Requester respectfully requests that the terms “Brandsford” and “Brandford”
and “Branford” also be searched in connection with this request to identify responsive records
that may have been the subject of these common misspellings.
To the extent Park City concludes that any portion of the records requested herein contain
any non-public information under GRAMA, I respectfully remind Park City of its affirmative
obligation under GRAMA to segregate information Park City legitimately believes is non-public
and to release the remainder, rather than withholding such records in their entirety. See Utah
Code § 63G-2-308.
I understand that GRAMA authorizes Park City to charge certain fees to respond to this
request, and Requester will pre-authorize up to $1,000 in fees. If fees are expected to exceed this
amount, please contact me before those fees are incurred. Requester may wish to exercise its
option to inspect records free of charge if that is the case, or to make additional arrangements for
payment. See Utah Code § 63G-2-203(5)(b). Before any records are compiled into a form other
than that normally maintained by Park City, please contact me to determine whether Requester is
actually seeking records in such form, as we do not believe the above request requires such work.
Requester may be reached through me at the following address: Parr Brown Gee &
Loveless, 101 South 200 East, Suite 700, Salt Lake City, Utah 84111. My telephone number is
801-257-7956, and my email address is jbrodis@parrbrown.com.
Feel free to contact me with any questions. Thank you for your prompt attention to these
matters.
Park City
November 23, 2021
Page 3
Sincerely,
PARR BROWN GEE & LOVELESS
/s/ Jeremy M. Brodis
Attorney for Requester